Help Center

How do I identify risk areas for contamination?

There are several scenarios that you might flag as at risk for contamination. Areas we often flag include:

• Facility co-storing organic and conventional ingredients
• Reuse of containers that store organic and non-organic product
• Sanitization of equipment and surface areas
• Areas where prohibited materials are stored or applied
• Equipment used for both organic and non-organic products

What do I need to know if I use a shared kitchen space?

If you use a commercial kitchen, or shared kitchen facility, you must communicate with all other users to identify their practices and materials (e.g., sanitizers) that require actions to prevent contamination. If multiple operations are producing organic products in a shared kitchen, consensus on pest control prevention methods and cleaning methods can help everyone and create consistency.

What are some contamination prevention strategies?

Each operation will need to meet unique needs with appropriate contamination prevention strategies. The first step is to take plenty of time to create best practices for higher risk areas. Common strategies for prevention include:

• Clear designation of storage areas for organic products, pest control substances, and cleaners
• Sealed, tamper evident and labeled packaging for shipping (when possible)
• Verification that transporters follow organic sanitation practices
• Plans for elimination and removal of cleaning and sanitizing residue

What is commingling?

Commingling is defined as the contact of organic products with non-organic products.

What are some risk areas for commingling?

In particular, split operations (operations that handle both organic and non-organic products) are at much higher risk for commingling.

Areas we often flag include:

• Facility co-storing organic and conventional ingredients
• Reuse of containers that store organic and non-organic product
• Equipment used for both organic and non-organic products

What are some strategies to prevent commingling?

Each operation will need to meet unique needs with appropriate commingling prevention strategies. Start by identifying your risk areas and actions. Common strategies for commingling prevention include:

• Clear designation of storage areas for organic products
• Clear and consistent labeling
• Staff education and awareness
• Plans for elimination and removal of cleaning and sanitizing residue
• Dedicated equipment for organic products

Can I use my equipment for both organic and non-organic products?

Yes. However, you’ll need to demonstrate and document a plan for purging and sanitizing equipment to prevent the commingling of organic and non-organic products.

When do I need to purge my equipment?

Purging applies to equipment used for both organic and non-organic products. It may also eliminate the step of equipment cleaning in certain situations.

A purge runs an adequate batch of organic product through equipment to eliminate any residue or remaining non-organic product in unreachable areas. All purged organic batches may not be sold as organic. They are eligible for sale as non-organic or may be discarded. Detailed records of equipment cleaning and purges are required.

When are equipment purges not required?

If you can adequately clean equipment prior to an organic run, or you are an organic-only facility, a purge is not required. Appropriate steps to eliminate cleaning material or sanitation residue are still necessary.

Which forms of pest control are allowed for my organic operation?

The USDA National Organic Program requires preventative pest management practices as a first measure in any area where organic products are handled, processed, or stored.

Commonsense pest prevention practices include:

• Removing potential habitat and food sources for pests
• Preventing pest access to the area where you work with organic product
• Controlling environmental conditions (e.g., temperature, light, etc.) to stop pest reproduction

What do I do if pest prevention methods are not enough?

If prevention methods are unsuccessful, you are eligible to use certain mechanical controls, such as traps, light or sound.

What do I do if pest prevention and mechanical methods fail?

Only after pest prevention and mechanical methods fail can you look to approved materials as a means for pest control. Never use a material unless it is approved for use per the National List and/or until after OTCO review and approval.

Some examples of National List approved materials include:

• Carbon dioxide
• Nitrogen
• Vitamin D3 bait
• Boric acid
• Diatomaceous earth
• Soap products

Under what circumstances can I use synthetic pest controls?

In rare scenarios where prevention, mechanical controls, and approved materials do not work, only then may you consider synthetic pest control methods. You will need OTCO approval prior to use.

To review your desired pest control method, we’ll need:

• Photocopies of the product label
• Manufacturer safety information sheet
• Demonstration of the need for use and documentation of failed preventative, mechanical and approved material pest control methods
• Clear plans for contamination prevention and documentation plan
• Updates to your Organic System Plan under pest management

Send information about all of the above to your client service team for review.

Can I co-store organic and non-organic products?

Yes. This is considered a “split operation,” or a facility that handles organic and non-organic products in one location.

When storing organic and non-organic products, you must prevent all organic product(s) from coming into contact with prohibited materials (e.g., sanitizers, pest control substances, etc.) or from commingling with non-organic product(s).

Can I store organic products in an uncertified facility?

If your product is packaged in a sealed, tamper-evident container and clearly labeled prior to storage, you may be able to use an uncertified storage facility. Your product can’t be processed while on-site at the non-certified facility. This includes no repackaging, relabeling, or introducing atmospheric modifiers such as ethylene.

The uncertified storage facility must fill out an Independent & Off-Site Storage (IS) form. The use of off-site storage locations must be disclosed in your Organic System Plan (OSP).

What do I need to know about storage during transport?

If you’re sending your product in a large container, you’ll need to provide verification that all cleaning methods of the container follow organic guidelines.

If you’re sending or receiving your product in permeable containers such as boxes or clamshells, you must provide verification from the shipping agent that it is protected from encountering prohibited gases, liquids, or materials.

Do I need to use a certified transporter?

No. You don’t need to use a certified organic transporter provided your product is sealed and clearly labeled prior to transporter receipt. It cannot be repackaged, relabeled or processed in any way — including use of restricted atmospheric controls — throughout the time of transport.

Are there restrictions if my organic product doesn’t come into contact with sanitizers?

You can use any sanitizer, disinfectant, or cleaner on food contact surfaces and equipment as long as it does not leave a residue or contact organic products, adding it to your Organic System Plan.

If you use a sanitizer that leaves a residue, you must thoroughly remove (and document your process) the residue by rinsing equipment with clean water — alcohol-based sanitizers must be air dried — before running any organic products.

What materials can I use when my organic product will come into contact with sanitizers?

Any sanitizer that may contact an organic product (such as no-rinse sanitizers used on food contact surfaces, or wash water additives) must be approved for use in organic.

For sanitation practices due to COVID-19:

• COVID-19 sanitizers that are organic-approved and EPA-listed include: hydrogen peroxide, peroxyacetic acid, sodium hypochlorite, and hypochlorous acid; isopropanol and ethanol are approved for sanitation during post-harvest handling activities.
• You can use OMRI-listed sanitizing products, following all restrictions, immediately.
• Review the USDA’s overview of Allowed Detergents and Sanitizers for Food Contact Surfaces and Equipment in Organic Operations
• There is no documented evidence of food-based transmission of COVID-19.

We encourage you to use OMRI’s search to see updated lists of approved sanitizers, cleaners and disinfectants for your use. Please note, use of an approved product must still follow all restrictions (if any). You must notify your client service team to add the products to your inputs list.

OMRI Approved Materials and Sanitizers Search

What are the requirements for quaternary ammonium compounds (quats or QACs)?

The high lingering residual effects for quats make them efficient and effective sanitizer solutions. However, quats are prohibited from coming into contact with organic products, ingredients, or packaging. You must perform a thorough rinse or alternative acceptable intervention to remove them from surface areas and equipment prior to organic production.

Following removal, you must use a low-ion test strip to verify that no quat residue is present. Your procedures and test results must be documented. Testing does not need to be performed each time provided you maintain — and record — the necessary pressure, temperature, quantity, and timing of the rinse as found in the initial zero residue test result. However, you must periodically test the efficacy of your procedures and provide ongoing documentation that your contamination prevention process is still effective.

Note that if you use quaternary ammonium sanitizers on shared equipment prior to non-organic production you must list these in the OSP section H5.

Test strip requirements:

• Must specifically test for residual quaternary ammonium
• Must have a match point at 0 ppm
• Next highest match point must measure 10 ppm or lower (more sensitive)
• Test result must be 0ppm prior to organic production

Illustrative list of acceptable test kits:

• LaMotte, 2934 Insta-TEST Dual Range QAC Test Strips
• Micro Essential Lab QL-110 Hydrion Lo Ion Quat Test Kits